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V2449-22 ·29 November 2022 ·consulta-vinculante Medium impact
Tax

Special regime for contribution of business lines may apply if economic autonomy requirements are met

The consultation asks whether the contribution of three distinct activities (service stations, vehicle repair, and property leasing) to new companies can qualify for the special regime under the Corporate Income Tax Act. The DGT rules that this is possible provided each set of assets constitutes an autonomous economic unit and the transaction is supported by valid economic reasons.

In 6 key points

How it affects those involved

Companies undertaking business restructuring through non-monetary contributions must ensure that each business line is economically independent and that the transaction is not driven solely by tax advantages.

Lifecycle

2022-11-29PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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